Wisconsin Medicaid Cost Reporting (WIMCR) and Comprehensive Community Services (CCS) Updates and Overview Wisconsin Human Services Financial Management Association (WHSFMA) Conference May 5, 2016 Public Consulting Group

Agenda 1. WIMCR & CCS Background 2. Cost Settlement Overview WIMCR & CCS Recap 4. Improvements to the 2015 WIMCR Cost Reporting Tool 5. WIMCR & CCS Guidance 6. Timeline and Next Steps 7. Centers for Medicare and Medicaid Services (CMS) Update 8. Contacts 9. Questions 2

WIMCR Background Requires annual cost reporting by enrolled public Medicaid providers (i.e. county agencies and local health departments) for certain services Brings additional federal funds into Wisconsin through cost based reimbursement methodology Payments made by Wisconsin Medicaid to counties are based on: Actual cost-based rate Units of service provided to Medicaid enrolled members A cost based reimbursement methodology determines the actual cost of delivering direct medical services 3

WIMCR Programs Adult Mental Health Day Treatment (Medical Day Treatment services) (AMHDT) Substance Abuse Day Treatment (SADT) Child Adolescent Day Treatment (CADT) Crisis Intervention (CI) Crisis Intervention (Stabilization) per diem (CI-SPD) Home Health (HH) Personal Care (PC) Outpatient Mental Health and Substance Abuse services (OPMHSA) Outpatient Mental Health and Substance Abuse in the Home and Community for Adults (OPMHSA-HC) Prenatal Care Coordination (PNCC) Targeted Case Management (TCM) Community Support Program (CSP) 4

CCS Background Mental health and substance abuse programs Provides programming to people of all ages—youth to elderly—living with a mental illness and/or substance use disorder CCS is for individuals who need ongoing services beyond occasional outpatient care, but less than the intensive care provided in a hospital setting The individual works with a dedicated team of service providers to develop a treatment and recovery plan to meet the individual's unique needs and goals A 2013 study of the consumer experience in CCS found that this targeted, community-based approach is effective in promoting better overall health and life satisfaction CCS reduces an individual's reliance on costly high-end services, such as emergency room visits. 5

Participating CCS Programs Prior to regionalization effective July 1, 2014 CCS Counties (31 counties including counties that are part of agencies) Non-CCS Counties 6

Participating CCS Programs Regional participation as of March counties and one tribe currently in CCS (includes Fond du Lac as non-regional participant) Color coding reflects 24 regional CCS entities: 18 county-based programs 3 population-based programs programs Multiple counties that have partnered together to form a separate legal entity operate a regional CCS program through the entity. 1 tribal-based program 7

Cost Settlement Overview 8

County Agency Overview Total cost and FTE information for the entire agency WIMCR Direct Service Checklist Programs, Provider IDs and Professional Types Direct Service and Support Salary and benefits by profession and service Supplemental Direct Service Information Additional information based on unique agency circumstances General Admin Overhead Allocation of agency overhead Federal Funds and Reductions Federal grant dollars applied to offset the cost of agency’s programs Summary and Certification Management Reports Provider Summary Reports and County Treasurer Reports 9

2014 WIMCR/CCS Recap

2014 WIMCR Cost Report Recap 99% Participation 77 Counties 112 Agencies 11

2014 WIMCR Cost Report Recap WIMCR Program Direct Service Direct Support Overhead AMHDT48.81%18.04%33.15% CSP53.35%30.13%16.53% CI55.78%31.90%12.32% CI-SPD100.00%0.00% HH38.59%34.71%26.70% OPMHSA45.81%34.94%19.25% OPMHSA-HC89.26%1.88%8.87% PC85.30%7.56%7.14% PNCC52.00%24.35%23.64% SADT28.22%55.81%15.96% TCM55.27%28.01%16.72% 12

Improvements to the 2015 WIMCR Tool CCS integration in the WIMCR tool 13

Direct Service Checklist Direct service checklist for Psychosocial Rehabilitation Psychosocial Rehabilitation services are provided to enable recipients to better manage the symptoms of their behavioral health issues, to increase their independence, and to achieve effective levels of functioning in the community and at home. Psychosocial rehabilitation services can provide services in an individual, family, or group setting. *Community Recovery Services (CRS) are currently not part of the cost settlement process. 14

Direct Service Checklist Direct service checklist with service level checklist 15

Direct Service Checklist Professional Types Professional Type Detail Professional detail selected and certification 16

Certification Page 17

WIMCR/CCS Guidance and Compliance 1. WIMCR/CCS Guidance A.Intergovernmental agreements B.Group participant units C.CCS start up costs 2. CMS Compliance Questions and Answers A.County agency overview guidance B.Overhead allocation for contractors C.Direct support and overhead personnel D.Federal funds and reductions E.Time Tracking F.Reasonable costs G.CRS updates 3. Community Aids Reporting System (CARS) Payments 18

WIMCR/CCS Guidance

1.A. - Intergovernmental Agreements Intergovernmental Agreements Terminology Intergovernmental Agreements: An intergovernmental agreement occurs when an employee of one county or tribal reporting entity provides services on behalf of a second reporting entity and the second reporting entity reimburses the first reporting entity for services provided. The graphic to the right shows an example of an intergovernmental agreement. Regional Shared: The term regional shared is used to identify an individual or a category of overhead used to support multiple counties. Revenue Offset: A revenue offset is the dollar amount paid from one county to another for services provided by a regional shared clinician or overhead provider. 20

Intergovernmental Agreements CCS counties have the flexibility to enter into contractual arrangements for service provision either among regional county entities or with non-county contractors. A region may contract with a county outside of the region for services. This outside county would be treated as a subcontractor and would not have a county section on the cost report. WIMCR counties may enter into contractual arrangements for service provision with neighboring counties. If counties or tribes opt to contract with other counties or tribes within their region each must report the appropriate revenues and expenditures to avoid double- counting costs. The county or tribe employing all shared staff: Reports total salary and benefits paid to each shared employee Reports a revenue offset for all contract revenue received from another county or tribe for services provided by the regional shared employee. Reports total hours for direct service or Full Time Employees (FTEs) for overhead, as well as an offset for hours worked on behalf of another reporting entity. The county or tribe which has contracted for a portion of the shared staff’s time: Reports contract cost that is paid to the county who is employing the shared staff. Reports hours (direct service) or FTEs (overhead) working for their county. 21

Direct Service Intergovernmental Agreements Example The example below demonstrates how a regional shared clinician should be reflected on the cost report of the county or tribe employing the shared clinician (County A) as well as the county or tribe contracting out for the shared clinician’s services (County B). 22

Overhead Intergovernmental Agreement Example The example below demonstrates how a regional shared overhead provider should be reflected on the cost report of the county or tribe employing the shared employee (County A) as well as the county or tribe contracting out for the shared employee’s services (County B). 23

1.B. - Group Participant Units Duplicated Participant Count terminology has transitioned to Group Participant Units Group Participant Units: the total number of participants attending all group services units. Example: For two CSP group sessions, one session has 11 participants and the other session has 15 participants. Assuming the sessions were for 15 minutes each, the total group participant units would be 26 units. Even if four participants attend both sessions, the total is still 26 units. Group 1: Participants x Units = 11 x 1 = 11 Group 2: Participants x Units = 15 x 1 = 15 Total: 26 Group Participant Units ProgramOne unit of group service CCS and CSP15 minutes OPMHSA and OPMHSA-HC1 hour PNCC (multiplied by the conversion factor for H1003) Unit is converted from 1 visit 24

Group Services Tracking Template 25

Group Services Tracking Template – PNCC Conversion Factor 26

1.C. - CCS Start up Costs Start up Costs: non-recurring costs associated with setting up a CCS program prior to the provision of direct services. *Unallowable start up costs per CMS direction. Allowable start up costs are the costs incurred after DQA certification of the CCS region Examples include equipment, program director, salary and hours, and rent Unallowable start up costs are incurred prior to DQA regional certification New regions must have DQA regional certification even if all the counties were DQA certified as single county programs 27

CMS Compliance Updates

2.A. County Agency Overview Page Question: How does CMS ensure that WIMCR/CCS costs align with each county’s single audit? Cost information on the County Agency Overview screen within the WIMCR/CCS cost report must align with total expenditures during the reporting period as documented in the county agency’s general ledger. Each county agency will need to attest that their cost report is in compliance with A-133 Single Audit Cost information: Personnel Expenditures and Operational Expenditures Must reflect all cost incurred by the county agency during the calendar year reporting period as documented within financial reports maintained by the county agency. Interdepartmental Charges Must reflect the portion of county wide overhead cost allocated to the county agency. Interdepartmental Charges reported must align with the county-wide cost allocation plan required by federal Cost Allocation Services. The method must be the same cost allocation method as performed county-wide under the cost allocation plan and must be supported by corroborating cost allocation documentation. * Agencies are required to submit general ledger pages that corroborate the expenditures listed on the County Agency Overview screen. 29

2.B. Overhead Allocation for Contractors Question: For WIMCR/CCS cost reporting, when may overhead be allocated to contractors? Counties may only allocate overhead costs to contractors if the allocation is consistent with the county’s cost allocation plan for central service costs. County-wide central service overhead and department overhead may only be applied to contractors, for WIMCR/CCS cost reporting purposes, if the county applies overhead rates to contractors according to the county-wide cost allocation service method, as well as according to the county government budget development method. The state will review county cost allocation plans at its discretion to verify consistency between the county-wide cost allocation plan method and the contractor allocated overhead method for WIMCR/CCS cost reporting. 30

2.C. Direct Support and Overhead Personnel Question: When is it appropriate to report overhead and direct support staff that are supervisory, administrative or clerical in nature? Supervisors and county administrative staff may be reported if the agency is in compliance with 2 CFR § 200, Subpart E, Section (c). Direct costs: The compensation of administrative and clerical staff may be reported if the employees meet the following conditions: administrative or clerical services are integral to a project or activity; individuals involved can be specifically identified with the project or activity, and these costs are not also recovered as overhead In accordance with Appendix VII 2 CFR § 200 D.1.a, “All departments or agencies of the governmental unit desiring to claim indirect costs [Direct Support and Overhead personnel] under Federal awards must prepare an indirect cost rate proposal and related documentation to support those costs”. Additionally, a non- federal entity may utilize a cost allocation plan if it is the case an indirect cost rate is not used. 31

2.D. Federal/State Funds and Reductions Question: When is it necessary to report federal funds and reductions? Items to report under Federal Funds and Reductions Any federal funding source received by a county and used to fund WIMCR costs Examples of federal funding sources that might need to be reported: Mental Health Block Grant Substance Abuse Block Grant Social Services Block Grant Birth to three allocation applied to WIMCR TCM Items to exclude from Federal Funds and Reductions xAny funding source that is not applied to any WIMCR cost xAny state funding that is used to cover the local share of WIMCR cost xMedicaid fee for service payments received - these will automatically be netted out of the final cost settlement as part of the Provider Summary Report (PSR) calculation xBasic County Allocation (BCA) xMaintenance of Effort (MOE) dollars 32

2.E. Time Tracking Question: How must counties ensure that they are accurately reporting and keeping records that reflect the division of direct service and direct support time/costs? Counties must have a method in place to segregate time/costs applicable to WIMCR/CCS services and maintain the records of the allocation of time. Counties may use the following options to track time. Other methods of time tracking must be approved by DHS prior to reporting. 1.Personnel activity reports (PAR) or employee day log 2.Time Studies (with CMS approval) Note: If a county opts to use a time study, they must submit their plan to the State during the reporting period and the State will verify the county methodology with CMS. CMS requires that approved time tracking methodology documentation must be maintained. Documentation must be available on request during monitoring reviews and financial audits. Without proper documentation, costs associated with Direct Service, Direct Support, and Overhead Personnel are unallowable costs 33

Time Tracking Personnel Activity Report (PAR) 34 Time tracking should capture the activities of every employee at each 15-minute interval for all hours worked. All time should be recorded including: WIMCR/CCS direct service WIMCR /CCS direct support Other Non WIMCR/CCS hours PTO hours

2.F. Reasonable Costs Question: What are allowable and reasonable cost for WIMCR/CCS reporting purposes? In order to be considered reasonable, costs shall not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. Reported cost must correspond to existing financial reports, county wide cost allocation plans and additional supporting documentation maintained by each entity for the reporting period. See 2 CFR 200 (herein referred to as OMB Circular A-87); and the Provider Reimbursement Manual, CMS Publication CFR 200 Provider Reimbursement Manual, CMS Publication In determining reasonableness of a given cost, OMB Circular A-87 states that consideration must be given to: Whether the cost is of a type generally recognized as ordinary and necessary for the operation and performance of the function for which the cost was incurred. The restraints or requirements imposed by such factors as sound business practices; arms-length transactions; Federal, State, and other laws and regulations; and terms and conditions of the Federal award or entitlement. Market prices for comparable goods or services. The necessity of contracting for the service, considering the governmental unit's capability in the particular area. Whether the service can be performed more economically by direct employment rather than contracting. Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the county agency, its employees, the public at large, and the Federal Government. Significant deviations from the established practices of the county agency which may unjustifiably increase the Federal awards’ cost. *The financial liability for fringe benefit and pension costs for retirees not associated with the ordinary and necessary operation of WIMCR/CCS programs are not considered reasonable costs. ** Room and board and the vaccines in VFC programs are not considered reasonable costs. 35

2.G. CRS Update Question: Has CRS obtained State Plan Approval? CRS is a mental health program with a focus on providing services to enable the individual to mitigate the impact of mental illness and live independently in the community and to reduce the incidence and duration of institutional treatment for mental illness. The 1915(i) State Plan Amendment (SPA) (09-017) articulates cost settlement/reconciliation for CRS. Wisconsin Medicaid has not yet completed this process with counties for any year for the program (2010-present) because we do not have a trial balance process approved with CMS. DHS continues to work with CMS on transitioning CSP (in WIMCR), CCS, and CRS into a single comprehensive psychosocial rehabilitation benefit by updating the Wisconsin SPA to receive authorization for the comprehensive program under Section 1905 authority. 36

CARS Update

3.A. CARS Update Normally, WIMCR receivables are moved from the prior year contract (in this case CY15) to the current year contract (in this case CY16) in January of each year before any CY16 payments are made. This move occurs on CARS profile It is done in January before any CARS runs are performed to allow counties to trace the calculated adjustment from the County Treasurer Reports (CTR) to CARS. For CY16, the WIMCR receivables were not moved from the CY15 to CY16 contracts in January due to an oversight. Instead, this receivable move on profile 1007 occurred on CARS voucher in May Because some of the CY15 receivable amounts had already been recouped against costs reported on the CY15 contracts between January-April, the May CARS voucher (90624) included a payment adjustment between contract years for the WIMCR receivable. Counties should have seen an increased payment on CY15 contracts for the amount that had been previously recouped against CY15 and a decreased payment on CY16 contracts for the corresponding amount. 38

Timeline and Next Steps Tentative Timeline for WIMCR/CCS Reporting CY2015 Cost Report 6/13/16 – 8/5/16 Desk Review for CY2015 8/5/16 – 9/2/16 In Person and Webex Trainings on CY2015 Cost Report 6/20/16 – 6/24/16 Management Reports of CY2015 9/5/16 – 12/19/16 39

Contact Us WIMCR Support Alissa Kordrupel Mitchell Perry Megan Morris (866) Additional Resources WIMCR Reporting Site: wimcr.com CCS Landing Page: wimcr.com/CCS DHS Contact Steve Milioto DHS Division of Healthcare Access and Accountability Phone:

Questions?